People v. Almanza, ___ Cal.App.4th ___, ___, ___ Cal.Rptr.3d ___, 2015 WL 368283 (6th Dist. Jan. 29, 2015) (In the context of a claim of conflict of interest ... the deficient-performance prong of the Strickland test is satisfied by a showing that defense counsel labored under an actual conflict of interest, that is, a conflict that affected counsel's performance"as opposed to a mere theoretical division of loyalties. (Rundle, supra, 43 Cal.4th at p. 169, 74 Cal.Rptr.3d 454, 180 P.3d 224, italics deleted.) In other words, defendant must show that the conflict (a) existed and (b) had some palpable, real effect on the trial, i.e., the actual conflict of interest adversely affected his lawyer's performance. ( Strickland, supra, 466 U.S. at p. 692, 104 S.Ct. 2052.)).
Cal Crim Def 20.39